Switzerland responds to liquidity management for VAT positions to manage COVID-19

Romy Mueller and Tim Reck of Deloitte Switzerland answer a series of frequently asked questions in relation to the SFTA’s COVID-19 response to VAT

The Swiss government and the Swiss Federal Tax Administration (SFTA) have responded to the COVID-19 crisis by taking the cash and liquidity demand of taxpayers into consideration and implementing various measures concerning VAT.

The interest rate on VAT (customs and excise duties) is reduced to 0.0% between March 20 2020 and December 31 2020. Nevertheless, interest on late VAT payments will still be invoiced for tax liabilities occurred outside the aforementioned period.
The Federal Financial Administration has officially asked the SFTA to speed up the process of auditing VAT receivables and to pay them out as quickly as possible, even though the payment deadline has not been reached. However, this needs to be applied for at the SFTA in particular.

The measures announced have raised a number of questions that have partly been addressed on the web page of the SFTA. However, there are also a number of items which have not been made clear so far. Below are some other frequently asked questions on the VAT developments.

Does the SFTA still announce/conduct VAT audits?

The SFTA has stopped on-site audit activities. Thus, taxable persons, for which an audit has been announced, should reach out to the SFTA and clarify next steps, including alternative timing. The SFTA considers conducting the audit of electronically provided documents. However, it remains unclear whether the audit quality will be comparable to an on-site audit and whether such an audit can be finalised.

Can VAT filing be postponed due to COVID-19?

The taxable person can generally apply for a deadline extension for three months. However, as the SFTA will generally remain operational, the measures taken should target to support cash flow management and should not support filing obligations per se. Thus, the SFTA is reluctant to extend the deadline to more than three months, unless an exception is decided via a single case-by-case assessment.

What can / needs to be done in case limited cash to settle a payable VAT return is available?

The taxable person can generally apply for a deadline extension for three months. In case a longer payment deadline is required, a written request needs to be submitted via a form (to be uploaded on the above referenced SFTA webpage) to the SFTA. The respective request can be filed by e-mail or physical mail.

Can the deadline for the VAT refund procedure (June 30) be extended as well?

The deadlines for the refund procedure are not extended, hence (to date) a refund procedure request has to be filed still within six months following the end of the previous calendar year according to Article 154 of the Swiss VAT Ordinance.

Tim Reck

T: +41 58 279 64 24

E: treck@deloitte.ch

Romy Mueller

T: +41 58 279 60 00

E: romymueller@deloitte.ch